Opinion of Nationally Recognized Accounting Firm. Valero shall have received an opinion from a nationally recognized accounting firm in form and substance satisfactory to Valero, in its sole discretion, to the effect that the Contribution and the Distribution, if effected, taken together, shall qualify as a transaction that is tax-free for U.S. federal income tax purposes under Sections 355 and 368(a)(1)(D) of the Code.
Appears in 4 contracts
Samples: Separation and Distribution Agreement, Separation and Distribution Agreement (CST Brands, Inc.), Separation and Distribution Agreement (CST Brands, Inc.)
